What’s happened: The National Security (Hostile States) Bill has received Royal Assent, officially passing into law.
- This grants the Home Secretary new counter-terrorism style powers to designate and target groups that are, according to a government press release, “working at the behest of, or in the interests of, foreign states in order to carry out acts which threaten the UK’s security and the safety of communities across the country.”
- Designation is equivalent to proscription as stipulated in the Terrorism Act 2000, but also applies to hostile state actors and their proxies.
- The new legislation criminalises assisting a designated body and obtaining material benefits from a designated body. It also includes supporting a designated body (where a person invites support for, or expresses an opinion or belief that is supportive of a designated body, and does so for a prohibited purpose).
- An individual convicted of these offences may be punished with a maximum sentence of fourteen years and a fine.
- The Home Secretary’s criteria for designation a group is if they “reasonably believe a body is, or has been, involved in foreign power threat activity and considers that designating the body is necessary to protect the safety or interests of the UK.”
- Commenting on the new law, the Home Secretary, Shabhana Mahmood said, “Under these new powers, we’re going further to dismantle and deter hostile activity. This act gives the police and intelligence agencies the tools they need to pursue foreign powers and their proxies, and better protect our communities, institutions, and democratic values.”
- Sir Ken McCallum, the Director General of MI5 said, “Building on the important powers in the National Security Act 2023, which are already being heavily used, this legislation introduces new measures which will help us tackle the growing threat from proxy organisations, which are being increasingly used by states attempting to deniably target the UK.”
Context: MI5 acknowledged a 35 per cent increase in 2025 from the previous year, and over 20 potentially lethal Iranian-backed plots were identified.
- The passage of The National Security (Hostile States) Bill follows a 2025 report by Jonathan Hall KC which highlighted the weaknesses in pre-existing legislation of The National Security Act 2023.
- That law had been used to charge, prosecute, and convict agents working for Iran, Russia, and China. However Hall argued it was “less effective at disrupting proxies than foreign intelligence services.” This conclusion led to Hall’s recommendation to introduce “State Threats Proscription-like Power”.
- The Bill was introduced in May’s King’s Speech. This followed a pledge by the Labour Party to take decisive action after waves of allegedly Iranian state-sponsored terrorism against the Jewish community in March and April. These attacks were claimed by Harakat Ashab al-Yamin al-Islamiyya (HAYI).
- Although some suspects were arrested shortly after the attacks took place, they were charged for arson and being reckless as to whether life would be endangered rather than through the Terrorism Act 2000 or National Security Act 2023. If found guilty, sentencing would therefore be significantly shorter and less severe, despite allegations of hostile state (specifically Iranian) direction.
- This had the effect of identifying a legal gap for hostile state activity by proxy, as was the case with HAYI. While HAYI had a presence on Telegram, it was widely described as being a “virtual” Iranian proxy group, as much as that it seemingly did not exist off social media, and was being remotely controlled and directed from the Middle East.
- Jewish community and Iranian dissident groups have consistently lobbied the government for IRGC proscription.
- The Conservatives pledged to proscribe the IRGC in 2023, but they ultimately U-turned and instead issued a new wave of sanctions against IRGC commanders.
- While in opposition, Labour had indicated it would be willing to proscribe the IRGC, and its 2024 manifesto made specific reference to taking “the approach used for dealing with non-state terrorism and adapt it to deal with state based domestic security threats.”
- After the recent wave of attacks in the spring, Labour reintroduced this policy with a renewed sense of urgency. While visiting the recently firebombed Kenton United Synagogue, Prime Minister Starmer pledged to table legislation allowing the UK to ban the IRGC in the upcoming parliamentary session.
Looking ahead: While the National Security (Hostile States) Bill never specifically mentioned the IRGC, it is highly likely to be the first group designated by Home Secretary.
- Given recent convictions of Russian and Chinese agents, it is also a realistic possibility that Moscow and Beijing’s security services – such as the SVR, GRU, FSB, and MSS – may also be designated.


